Act 2014 – Consultation on the Regulations and

Implementation of the Social Services and
Well-being (Wales) Act 2014 - Consultation on
the Regulations and statutory guidance in
relation to Part 9 (Co-operation and Partnership)
of the Act
A Response from Neath Port Talbot CVS
July 2015
Neath Port Talbot CVS
Tŷ Margaret Thorne
17-19 Alfred Street
Neath
SA11 1EF
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A response to the Implementation of the Social Services and
Well-being (Wales) Act 2014 - Consultation on the Regulations and
statutory guidance in relation to Part 9 (Co-operation and
Partnership) of the Act
Neath Port Talbot Council for Voluntary Service (CVS)
Neath Port Talbot CVS is the County Voluntary Council and a Charitable Company
set up to promote, support and develop the Third Sector in Neath Port Talbot. It has
over 500 member organisations and is in touch with over 1,000 Third Sector
organisations operating in Neath Port Talbot.
The organisation has strong partnership links locally and regionally and works in a
number of strategic areas, such as Health, Regeneration, Children & Young People.
As part of this work, Neath Port Talbot CVS facilitates the Regional Health, Social
Care and Wellbeing Network and the Neath Port Talbot Health, Social Care and
Wellbeing Forum. Neath Port Talbot CVS also promotes a range of health messages
to its staff and to the wider community through its networks, newsletters, website and
social media.
Neath Port Talbot CVS has made this consultation document available on its website
and through its general information services.
Neath Port Talbot CVS welcomes the opportunity to respond to this consultation.
Response:
Neath Port Talbot CVS would like to make the following general comments regarding
the consultation, prior to responding particular areas of the consultation.
 The consultation proposes a new structure. What will happen to the current
structures that are in place through the Western Bay Health and Social Care
Programme? Will these be dismantled or duplicated?
 How will Local Government reorganisation impact on the implementation of the
Act?
 The Act is being implemented at a time of austerity. How will this impact on the
implementation of the Act?
Role and Proposed Membership of the Regional Partnership Boards (RPBs):
 Greater clarity is required around the membership of the RPB. Whilst it is
recognised that the guidance gives scope for local implementation, the use of ‘at
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least one’ is ambiguous. It should either be one person representing the whole area
or one person representing each local authority area for all the members listed as
at least one. This would ensure that representation is proportionate and fair. It
should not be the case, for example, that there could be three elected members,
and only one person representing the third sector, at the RPB.
It is also important to recognise that the total membership of the Board is not so
large that meetings are unmanageable and it is difficult for decisions to be made.
It would be appropriate for a County Voluntary Council (CVC) for represent that
interests of the third sector in the area covered by the RPB. This arrangement is in
place in Western Bay, with one CVC Director representing for the three CVCs
covered by Western Bay. The CVC has a long recognised role in engaging with the
Sector, representing and reflecting the views of the Sector at key strategic
meetings, and appropriate mechanisms are already in place to gain the views and
ensure feedback to the Sector, in this case through the Regional Third Sector
Health, Social Care and Wellbeing Network.
Given the impact of housing on the health and social care agenda, housing should
be represented at the RPB.
The proposal that a lay person is appointed by Welsh Ministers by public
appointment is inappropriate. It is proposed that this lay person could be a member
of the regional citizens’ panel, and feed in citizens’ views. This would not be
feasible if they are nominated by Welsh Ministers. If there is to be a representative
of the citizens’ panel at the RPB, it should be nominated by the panel itself; it
should not be appointed by Welsh Ministers.
There needs to be greater clarity around the role of the citizens’ panel and how it
feeds in views and receives feedback from the RPB. How will it work? It is also
important to consider that service user groups may have different views which may
contradict.
Citizens and service users must have a strong voice at the RPB and able to inform
and influence decision making.
Pooled Funds:
 Will pooled funds have an impact on Third Sector funding? Could this impact be
negative as funding is pulled in house or will greater co-operation and partnership
lead to more funding support for the Third Sector? It is important to note that the
Act cannot be implemented without the support of the Sector, and it is therefore
hoped that this could lead to additional support for the Sector.
Priority Areas:
 Mental health is a key priority area which should be considered, particularly with
regards to the early prevention and intervention agenda and for those people who
don’t traditionally meet the threshold for services.
 There is no reference to the Mental Health Measure throughout the Act, and there
is little mention of mental health. If it is assumed that this is to be picked up through
the Measure, there needs to be clear reference to it within the Act. However, as the
Measure does not pick up early intervention and prevention, this should be a focus
of the Act.
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 It should be noted that work around early intervention and prevention has been
picked up through the Western Bay Health and Social Care Programme. As it
hasn’t been identified as a priority area, would this work continue? Would this focus
shift to the prescribed priority areas to the detriment of this work?
Improved Outcomes:
 It is hoped that the Act and its approach and focus on an individual’s needs will lead
to improved outcomes. The challenge will be in shifting the agenda upstream to
promoting wellbeing and giving people control over their own lives.
 There is a need to consider how improved outcomes are monitored; the focus
should not solely be on recording performance indicators, but on knowing the
differences that have been made to people’s lives.
Re-prioritisation of resources:
 Funding to enable the shift upstream would be beneficial, especially as it places
greater reliance and demand on third sector services.
 Statutory services need to consider how they discharge their responsibilities. They
cannot signpost and refer to third sector services without providing the resource
required to meet additional demand.
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